ATTACHMENT 1

To NPS/FWS Comments - Maine Draft Regional Haze SIP

NPS Comments Regarding Verso Androscoggin Paper Mill BART Evaluation

July 23, 2010

Power Boilers #1 & #2: NOx

The following statement by Verso is misleading:

The Androscoggin Mill followed the guidance and procedures outlined in 40 CFR Part 51, 

Appendix Y and the OAQPS Air Pollution Cost Control Manual. Supporting cost evaluation 

spreadsheets are provided in Attachment C, Table Nos. C-1, C-2, C-3, and C-4.

While we applaud Verso’s intent to use the Cost Manual, the actual Verso approach appears to 

have borrowed the Cost Manual method for evaluating wet scrubbers and applied it to SCR and 

SNCR, which we believe is inappropriate.

In actuality, there is no OAQPS Air Pollution Cost Control Manual (Cost Manual) procedure for 

evaluating costs for SCR or SNCR for oil-fired EGUs. The procedures described by the Cost 

Manual are intended for use with coal-fired boilers > 250 mmBtu/hr. So we adapted them to oilfired boilers, but the cost algorithms for the Direct Capital Costs are from the Cost Manual coalboiler method and therefore questionable.

Even if we accept the Verso approach as a default, it still contains some highly questionable 

estimates for SCR, and Verso clearly did not follow the Cost Manual:

 If we assume that Power Boilers #1 & #2 are capable of producing about 68 MW each, 

then the Total Capital Investment (TCI) per kW is about $115 for SCR, which is in the 

middle of the $50 - $260/kW range for coal-fired EGUs. The attached Excel workbook 

estimates a slightly higher TCI by applying our adapted Cost Manual approach.

 Verso has estimated an annual reagent cost of $414,000/boiler. This exceeds the $54,000 

annual reagent cost that the Cost Manual procedure estimates. Verso must justify this 

estimate.

 Verso has estimated an annual catalyst replacement cost of $155,000/boiler. Since this 

exceeds the $92,000 annual catalyst replacement cost that the Cost Manual procedure 

estimates for the 330 MW Naughton Unit #3 (that Wyoming is requiring to install SCR 

as BART), the Verso estimate appears to be very high. Our adapted Cost Manual method 

estimates catalyst volume at 88 m3, a 24,000 hour catalyst life, and an annual Catalyst 

Replacement Cost = $41,000/boiler. Furthermore, because most catalyst vendors do not 

charge for recovery of the spent catalyst, that $30,000 annual cost also appears 

unfounded.

 Verso's Capital Recovery Factor (12.4% interest over a 10-year SCR life) is inflated. The 

Cost Manual recommends 7% interest over a 20-year SCR life.

 Verso estimates an annual cost of $5.1 million to control both boilers1versus our estimate 

of $1.1 million for each boiler, and Verso estimates $7,361/ton versus our $3,070/ton.

 

1 Verso assumed a $0.08/kWh cost for electricity.
According to Maine Department of Environmental Protection (MEDEP):

The cost effectiveness numbers in the table above are based on controlling NOx emissions 

from Power Boilers #1 and #2 at the control effectiveness rates indicated in the table 

from the highest estimated two year average annual emissions between 2002 and 2008. 

In recent years (2008 and 2009) these boilers have been operating close to only 20% of 

the time, which for example, would result in an actual cost effectiveness of $16,313 per 

ton of NOx removed with the installation of SCR. 

MEDEP estimates cost-effectiveness at $5,271/ton versus the $7,361/ton estimated by Verso; we 

request an explanation for this difference. Furthermore, if MEDEP intends to consider the 

reduced operation of these boilers in the economic analysis, those reduced operational 

parameters should be made federally enforceable if they affect the outcome of the analysis.

Because BART is a visibility improvement program, we believe that cost/deciview ($/dv) is a 

very important parameter. In this case, for the four Class I areas evaluated by Verso, SCR would 

improve visibility by a total of 4.6 dv. (We would also like to see the visibility improvements 

that would occur in the other two Class I areas.) This results in a cost-effectiveness value of less 

than 0.5 million/dv, which is quite reasonable compared to the average $13 - $20 million/dv that 

we are seeing accepted by states and sources that are proposing reductions under BART. Even if 

one considers only the visibility improvement at Acadia National Park, the addition of SCR 

results in a cost-effectiveness value of $1.3 million/dv. This leads to the conclusion that SCR is 

BART for the Androscoggin power boilers.

The same situation applies to SNCR. The actual Verso approach appears to have borrowed the 

Cost Manual method for evaluating wet scrubbers and applied it to SNCR, which we believe is

inappropriate. Even if we accept the Verso approach as a default, it still contains some highly 

questionable estimates for SNCR:

 If we assume that Power Boilers #1 & #2 are capable of producing about 68 MW each, 

then the Total Capital Investment (TCI) per kW is about $47 for SNCR, which is on the 

high end of the $29 - $45/kW range we are seeing in proposals to install SNCR on coalfired EGUs (See http://www.wrapair.org/forums/ssjf/bart.html). The attached Excel 

workbook estimates $26/kW. Verso should provide vendor quotes to support its higherthan expected estimates.

 Verso has estimated a Direct Annual Cost (DAC) of $0.55 million/boiler. Since this 

exceeds the $0.12 million DAC that the Cost Manual procedure estimates, the Verso 

estimate appears to be very high. The biggest difference is in Verso's estimate of almost 

$0.5 million/year/boiler for reagent versus the Cost Manual estimate of $0.06 million/yr.

 Verso's Capital Recovery Factor (12.4% interest over a 10-year SNCR life) is inflated. 

The Cost Manual recommends 7% interest over a 20-year SCR life.

 Verso estimates an annual cost of $2.6 million to control both boilers2versus our estimate 

of $0.29 million for each boiler, or Verso's $9,758/ton versus our $2,128/ton.

MEDEP estimates cost-effectiveness at $5,973/ton versus the $9,758/ton estimated by Verso; we 

request an explanation for this difference. 

 

2 Verso assumed a $0.08/kWh cost for electricity.
In this case, for the four Class I areas evaluated by Verso, SNCR would improve visibility by a 

total of 4.3 dv. (We would also like to see the visibility improvements that would occur in the 

other two Class I areas.) This results in a cost-effectiveness value of less than 0.13 million/dv, 

which is quite reasonable compared to the average $13 - $20 million/dv that we are seeing 

accepted by states and sources that are proposing reductions under BART. Even if one considers 

only the visibility improvement at Acadia National Park, the addition of SCR results in a costeffectiveness value of $0.41 million/dv. This leads to the conclusion that SNCR could also be a 

candidate for BART for the Androscoggin power boilers if SCR is rejected.

Power Boilers #1 & #2: SO2

Some comments on Verso's BART analysis for SO2 from the Androscoggin mill Power Boilers 

#1 & #2.

Power Boilers #1 & #2 wet scrubber cost analysis

 Verso's Purchased Equipment Costs are not supported or justified.

 Is there a state sales tax exemption for pollution control equipment?

 Verso's Maintenance costs are not supported or justified.

 Verso's Utilities costs are not supported or justified.

 Can Verso use waste caustic from the mill to augment caustic purchases? (We are seeing 

this at other mills.)

 Verso's annualized costs do not make sense--the numbers do not work out as presented.3

 Verso overestimated the interest rate and underestimated equipment life. According to the 

OAQPS Control Cost Manual, the correct interest rate is 7% and the correct equipment 

life is 15 years.

Verso's Power Boilers #1 & #2 lower sulfur fuels analysis is incomplete. For example,4FPL

evaluated 1%S residual, 0.5% S residual and 0.3% S residual fuel oils for its Wyman facility,

Verso should at least evaluate the lower sulfur residual oils.

Waste Fuel Incinerator (WFI): NOx

We adapted the OAQPS Air Pollution Cost Control Manual (Cost Manual) procedure for 

evaluating costs for SCR or SNCR for oil-fired EGUs to oil-fired EGUs (see electronic 

attachment), but the cost algorithms for the Direct Capital Costs are from the Cost Manual coalboiler method and therefore questionable. So, even if we accept the Verso approach as a default, 

it still contains some highly questionable estimates for SCR:

 If we assume that the WFI is capable of producing about 48 MW, then the Total Capital 

Investment (TCI) per kW is about $165 for SCR, which is in the middle of the $50 -

$260/kW range for coal-fired EGUs. The attached Excel workbook estimates a slightly 

lower TCI.

 

3 Verso assumed a $0.08/kWh cost for electricity.

4

In Massachusetts, sources evaluated 1%S residual, 0.5% S residual, 0.3% S residual, 0.3% S distillate, 0.05% S 

distillate, and 0.0015% S distillate.
 Verso has estimated an annual reagent cost of $286,000. This exceeds the $72,000 annual 

reagent cost that the Cost Manual procedure estimates. 

 Verso's Capital Recovery Factor (12.4% interest over a 10-year SCR life) is inflated. The 

Cost Manual recommends 7% interest over a 20-year SCR life.

 Verso estimates an annual cost of $2.4 million to control the WFI5versus our estimate of 

$0.9 million, or Verso's $5,092/ton versus our $1,986/ton.

MEDEP estimates cost-effectiveness at $4,676/ton versus the $5,092/ton estimated by Verso; we 

request an explanation for this difference. 

Because BART is a visibility improvement program, we believe that cost/deciview ($/dv) is a 

very important parameter. In this case, for the four Class I areas evaluated by Verso, SCR would 

improve visibility by a total of 1.0 dv. (We would also like to see the visibility improvements 

that would occur in the other two Class I areas.) This results in a cost-effectiveness value of less 

than $1 million/dv, which is quite reasonable compared to the average $13 - $20 million/dv that 

we are seeing accepted by states and sources that are proposing reductions under BART. Even if 

one considers only the visibility improvement at Acadia National Park, the addition of SCR 

results in a cost-effectiveness value of $2.3 million/dv. This leads to the conclusion that SCR is 

BART for the Androscoggin WFI.

The same situation applies to SNCR. So, even if we accept the Verso approach as a default, it 

still contains some highly questionable estimates for SNCR:

 Although Verso stated that SNCR could achieve 35% control, its cost analysis is based 

upon 30% control.

 If we assume that the WFI is capable of producing about 48 MW, then the Total Capital 

Investment (TCI) per kW is about $65 for SNCR, which is above the high end of the 

$29 - $45/kW range we are seeing in proposals to install SNCR on coal-fired EGUs. The 

attached Excel workbook estimates $31/kW. Verso should provide vendor quotes to 

support its higher-than expected estimates.

 Verso has estimated a Direct Annual Cost (DAC) of $0.41 million. Since this exceeds the 

$0.13 million DAC that the Cost Manual procedure estimates, the Verso estimate appears 

to be high. The biggest difference is in Verso's estimate of almost $0.34 million/year per 

boiler for reagent versus the Cost Manual estimate of $0.07 million/yr.

 Verso's Capital Recovery Factor (12.4% interest over a 10-year SNCR life) is inflated. 

The Cost Manual recommends 7% interest over a 20-year SNCR life.

 Verso estimates an annual cost of $1.1 million to control the WFI6versus our estimate of 

$0.27 million, or Verso's $7,009/ton versus our $1,757/ton.

MEDEP estimates cost-effectiveness at $5,944/ton versus the $7,009/ton estimated by Verso; we 

request an explanation for this difference. 

In this case, for the four Class I areas evaluated by Verso, SNCR would improve visibility by a 

total of 0.2 dv. (We would also like to see the visibility improvements that would occur in the 

 

5 Verso assumed a $0.07/kWh cost for electricity.

6 Verso assumed a $0.07/kWh cost for electricity.
other two Class I areas.) This results in a cost-effectiveness value of less than 1.4 million/dv, 

which is quite a bargain compared to the average $10 - $20 million/dv that we are seeing 

accepted by states and sources that are proposing reductions under BART. Even if one considers 

only the visibility improvement at Acadia National Park, the addition of SCR results in a costeffectiveness value of $2.7 million/dv. This leads to the conclusion that SNCR could also be a 

candidate for BART for the Androscoggin power boilers if SCR is ruled out.

Waste Fuel Incinerator (WFI): SO2

This is what Verso says about SO2 BART for the Androscoggin Waste Fuel Incinerator:

When No. 6 fuel oil is fired at significant levels, the Mill adds caustic to the wet scrubber to 

meet the SO2 emission limit for the WFI. 

SO2 BART ANALYSIS

Identify BART

The WFI has very low SO2 emissions due to the inherent alkalinity (i.e., SO2 control) of the 

primary fuel and the small amount of fuel oil used in the WFI. In addition during the limited 

amount of time that No. 6 fuel oil is used to provide a significant amount of the heat for the 

WFI, caustic is added to the wet scrubber. Since there are only 50 tons of SO2 to control 

annually, the addition of caustic to the wet scrubber would end up controlling a very small 

amount of emissions on an annual basis. Considering visibility, the low, pre-control visibility 

impacts from the WFI mean that any visibility reductions associated with post-control of SO2 

emissions would be imperceptible. Based on the information developed in the Impacts 

Analysis, the Androscoggin Mill believes that there is no SO2 BART determination for SO2 

from the WFI.

Is Verso saying that it does not want its current procedure of adding caustic to the wet scrubber 

when burning fuel oil to be considered BART, but will keep doing it anyway? If so, that is 

clearly wrong because BART would include this practice as a technically- and economicallyfeasible option, as proven by Verso. Finally, a control option does not have to produce a 

perceptible improvement to be viable.
ATTACHMENT 2

To NPS/FWS Comments - Maine Draft Regional Haze SIP

NPS Comments Regarding FPL Energy Wyman Station BART Evaluation

July 20, 2010

Beginning in 2006, capacity utilization of, and emissions from Units #3 & #4 dropped so much 

that, assuming that trend continues, it would likely be cost-prohibitive to make any substantial 

capital expenditures to reduce emissions. Furthermore, as noted by Maine Department of 

Environmental Protection (MEDEP), NOX emissions are already so low as to make any 

significant additional expenses economically infeasible. So, we shall focus our comments on 

reducing SO2 emissions by switching to lower sulfur fuels.

SO2

This appears to be the only BART analysis conducted by MEDEP in which cost-effectiveness 

was not evaluated in terms of annual cost/ton of pollutant removed. Instead, MEDEP appears to 

have relied solely upon annual cost/deciviews (dv) of visibility improvement. While we 

encourage the use of the $/dv metric, it was not properly calculated nor applied in this case.

MEDEP also evaluated the BART strategies on the basis of incremental cost/dv. While that is 

certainly a valid and useful parameter, it must be used with caution and its results placed into the 

proper perspective. The basic premise underlying the incremental cost analysis is to identify 

those strategies that contribute relatively little environmental benefit in proportion to their cost. 

Because, in most cases, the cost of pollution control rises exponentially with control efficiency, 

the slope of the cost curve will also increase. For this reason, rigid use of incremental cost 

effectiveness will always result in the choice of the cheapest option if carried to its ultimate

extent. (For example, if this approach were used to evaluate PM controls, it is likely that all 

controls more expensive than a multiple cyclone would be rejected.) According to the NSR 

Workshop manual, “As a precaution, the difference in incremental costs among dominant 

alternatives cannot be used by itself to argue one dominant alternative is preferred to another.” 

Instead, it should be used to compare closely performing options.7

However, FPL did evaluate the costs and benefits of several SO2 reduction options, including the 

use of lower sulfur fuels. In doing so, FPL included estimates of the annual costs and emission 

reductions for each option, as well as the cost/ton for each of those options; those results are 

contained in Tables 5-3 thru 5-5 of the FPL BART analysis. We used the data from FPL’s Table 

5-3 to generate the cost-benefit data contained in the electronic attachment, and our results are 

summarized below.

 

7BART Guidelines: “You should consider the incremental cost effectiveness in combination with the average cost 

effectiveness when considering whether to eliminate a control option” and “You should exercise caution not to 

misuse these [average and incremental cost effectiveness] techniques...[but consider them in situations where an 

option shows]...slightly greater emission reductions...”
Wyman #3 (2007 - 2008)

Fuel Sulfur (%) 1 0.7 0.5 0.3

Increased Annual Fuel Cost $ 175,306 $ 206,243 $ 835,283 $ 1,722,127 

SO2 Emission Reductions (tpy) 270 351 405 459

SO2 Reductions Cost-Effectiveness ($/ton) $ 650 $ 588 $ 2,064 $ 3,755 

Greatest Visibility Improvement (dv) 0.99 1.43 1.78 2.15

Cost-Effectiveness ($/dv) $ 177,077 $ 144,226 $ 469,260 $ 800,989 

Cumulative Visibility Improvement (dv) 2.61 4.26 5.26 6.28

Cumulative Cost-Effectiveness ($/dv) $ 67,167 $ 48,414 $ 158,799 $ 274,224 

Wyman #4 (2007 - 2008)

Fuel Sulfur (%) 0.5 0.3

Increased Annual Fuel Cost $ 2,910,880 $ 7,014,743 

SO2 Emission Reductions (tpy) 250 499

SO2 Reductions Cost-Effectiveness ($/ton) $ 11,656 $ 14,045 

Greatest Visibility Improvement (dv) 0.41 0.84

Cost-Effectiveness ($/dv) $ 7,099,707 $ 8,350,885 

Cumulative Visibility Improvement (dv) 1.60 3.38

Cumulative Cost-Effectiveness ($/dv) $ 1,819,300 $ 2,075,368 

Our results differ from those presented by MEDEP because we used the most-recent (2007 –

2008) average fuel use data provided by FPL instead of the maximum two-year average. We did 

this because the most-recent two years are much more representative of anticipated reduced 

operation of these units. While use of the reduced-capacity operation data did not affect the $/ton 

estimate (which MEDEP did not include), it has a great effect on the $/dv estimate because of the 

reduced annual costs.

Our results indicate that, on a $/ton basis, use of 0.7% sulfur oil is the most cost-effective. 

However, BART is not necessarily the most cost-effective solution. Instead, the $2,000/ton cost 

of switching Unit #3 to 0.5 % sulfur oil would be considered reasonable by most states.

As noted above, MEDEP appears to have relied solely upon $/dv of visibility improvement. 

However, the baseline for estimating the increased costs of lower sulfur fuels (2% sulfur) is 

different from the baseline for existing visibility impacts (1.6% S). Therefore, the visibility

benefits are underestimated because the baseline impacts are underestimated. MEDEP has also 

presented 98th percentile visibility values despite using only one year of meteorological data—

that is misleading because, when only one year is modeled, only the maximum values are to be

used.

Because BART is a visibility improvement program, we believe that cost/deciview ($/dv) is a 

very important parameter. In this case, for the six Class I areas evaluated by FPL, lower-sulfur 

(0.5% - 0.3% S) fuels would improve visibility by a total of 6.9 – 9.7 dv. This results in a costeffectiveness value of $0.2 – 2.1 million/dv, which is relatively inexpensive compared to the 

average $13 - $20 million/dv that we are seeing accepted by states and sources that are proposing 

reductions under BART. Even if one considers only the visibility improvement at Acadia 
National Park, the lower-sulfur fuels result in cost-effectiveness values of $0.5 – 8.4 million/dv. 

This leads to the conclusion that 0.5% - 0.3% sulfur fuels are BART for the FPL boilers.
ATTACHMENT 3

To NPS/FWS Comments - Maine Draft Regional Haze SIP

NPS Comments Regarding SAPPI SD Warren Paper Mill BART Evaluation

July 20, 2010

Page 63 of the 2/06/09 draft of Maine Department of Environmental Protection (MEDEP) RH 

SIP contains Table 8-2 titled "Modeled Impacts...of Maine BART-Eligible Sources..." That table 

shows a 0.75 dv impact at Acadia and 0.78 dv at Moosehorn from Power Boiler #1 at the SAPPI 

SD Warren Paper mill. 

The September 2009 company BART report did not evaluate Power Boiler #1.

The MEDEP BART analysis (1/21/10) listed Power Boiler #1 as a BART source and included a 

BART determination for it. 

The MEDEP BART analysis (posted 6/29/10) did not mention Power Boiler #1. 

Why was Power Boiler #1 omitted from the BART determination?